Privacy Policy
1. Who we are
This website (https://ordn.co.uk) is operated by ORDN (“ORDN”, “we”, “us”, “our”).
ORDN provides AI-native lending infrastructure for whole loans, securitised credit and refinancing, connecting Capital Partners and Brokers through our platform (the “Platform”).
We are committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, share and protect personal data in connection with our website, our Platform, and our dealings with Capital Partners, Brokers, and other users, in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
For the purposes of data protection law, ORDN is the data controller of personal data collected via this website and in connection with our own business relationships. Where ORDN processes personal data relating to borrowers or loan applicants on behalf of Capital Partners or Brokers, ORDN typically acts as a data processor, and the relevant Capital Partner or Broker remains the data controller—see Section 9.
2. Contact us / Data Protection contact
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at:
- Email: hello@ordn.co.uk
3. Personal data we collect
The personal data we collect depends on how you interact with us. This may include:
a) Visitors to our website
- Technical data such as IP address, browser type and version, device information, time zone, operating system, and browsing actions (see our Cookie Policy).
- Information you provide when you contact us or submit an enquiry, such as your name, email address, company name and the content of your message.
b) Capital Partners and Brokers (and their personnel)
- Contact details, including name, job title, business email, phone number and organisation.
- Login and account credentials for the Platform.
- Information relating to your use of the Platform, including buy-box criteria, portfolio configurations, communications and audit trail activity.
- Billing and commercial information where relevant to our agreement with you.
c) Loan applicants / borrowers (processed on behalf of our clients)
Where ORDN sources, underwrites, or services loans on behalf of a Capital Partner or Broker, we may process identity and contact details; financial information; property or security-related information; information from credit reference and fraud prevention agencies; and communications and documents submitted as part of a loan application.
We process this data as a processor, strictly in accordance with the instructions of, and the agreement with, the relevant Capital Partner or Broker. Loan applicants and borrowers should first contact the Broker or Capital Partner they applied through.
We do not knowingly collect special category data except where necessary and permitted by law, and only where instructed by, and on behalf of, the relevant controller.
4. How we collect personal data
We collect personal data:
- Directly from you, when you fill in a form, register for the Platform, contact us, or communicate with us.
- Automatically, as you interact with our website and Platform (see our Cookie Policy).
- From third parties, including Capital Partners, Brokers, credit reference agencies, fraud prevention agencies, identity verification providers, and publicly available sources.
5. How and why we use your personal data
| Purpose | Legal basis (UK GDPR Article 6) |
|---|---|
| Operating and maintaining our website | Legitimate interests |
| Responding to enquiries and communications | Legitimate interests / pre-contractual steps |
| Providing and supporting the Platform | Performance of a contract; legitimate interests |
| Onboarding and account administration | Performance of a contract; legitimate interests |
| Sourcing, underwriting and servicing loans, including AI/ML-assisted tools and analytics | Performance of a contract on behalf of our clients; legitimate interests |
| Credit and affordability checks, fraud prevention, AML / KYC checks | Legal obligation; legitimate interests |
| Maintaining audit trails, records and reporting | Legal obligation; legitimate interests |
| Marketing communications | Consent, or legitimate interests, subject to your right to opt out |
| Regulatory, tax and legal compliance | Legal obligation |
| Improving our website and Platform, including analytics | Legitimate interests, or consent where required |
6. Automated decision-making and profiling
Our Platform uses AI and machine-learning tools, including our “Loan Factory” product design tool, to assist Capital Partners with designing loan products and to support underwriting, portfolio analytics, and identification of deviations from agreed lending criteria.
Loan placement decisions are made against buy-box criteria set by Capital Partners, who may grant ORDN deviation approval authority within defined parameters. Where a decision producing legal or similarly significant effects is made without meaningful human involvement, you have rights under UK GDPR, including requesting human intervention, expressing your point of view, and contesting the decision.
7. Sharing your personal data
We may share personal data with:
- Capital Partners and Brokers, in connection with their loan products and services.
- Credit reference agencies and fraud prevention agencies.
- Service providers and sub-processors, including cloud, IT, AI/ML, analytics, email and communications providers.
- Professional advisers, including lawyers, auditors and insurers.
- Regulators, law enforcement and government bodies, where required.
- A buyer or successor, following a merger, acquisition, restructuring or sale.
We do not sell personal data to third parties.
8. International data transfers
Some service providers may process data outside the UK. Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place, such as UK adequacy regulations, UK International Data Transfer Agreements or Addendums, or recognised Standard Contractual Clauses. You can request further details by contacting us.
9. Our role as processor for client data
Where ORDN processes personal data relating to loan applicants, borrowers or other individuals on behalf of a Capital Partner or Broker, ORDN acts as a data processor and the relevant Capital Partner or Broker is the data controller. ORDN:
- processes personal data only on documented instructions;
- implements appropriate technical and organisational security measures;
- assists the controller with data subject requests and regulatory obligations; and
- does not use data for independent purposes except as permitted under the relevant agreement.
If you are a borrower or loan applicant, your primary contact is the Capital Partner or Broker through which you applied.
10. Data retention
We retain personal data only as long as necessary, including to satisfy legal, accounting, regulatory or reporting requirements. Lending-related records may need to be retained for a number of years after a loan or business relationship ends. Where we act as processor, retention periods are generally determined by our agreement with the controller.
11. Security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, alteration, disclosure or destruction, including access controls, encryption and audit trails. However, no method of transmission or storage is completely secure.
12. Your rights
Subject to applicable law, you have the right to:
- request access to and correction of your personal data;
- request erasure, restriction or portability;
- object to our processing;
- withdraw consent where processing is based on consent; and
- not be subject to qualifying solely automated decisions.
To exercise these rights, use the contact details in Section 2. You may also complain to the Information Commissioner’s Office (ICO): ico.org.uk or 0303 123 1113.
13. Cookies
Our website uses cookies and similar technologies. For full details, see our Cookie Policy.
14. Children’s data
Our website and Platform are intended for business use and are not directed at children. We do not knowingly collect personal data from children.
15. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or for legal, operational or regulatory reasons. We will post the updated version on this page.
16. Contact us
ORDN
Email: hello@ordn.co.uk